Owners, controllers, and beneficiaries

When you open a bank account with Griffin, you need to tell us who has what rights and permissions regarding that account.

You do this by assigning legal persons to the following relationships.

• Owner. The legal person who is ultimately responsible for the bank account and how it used, but doesn’t necessarily interact with it directly.
• Controller. The legal person we accept instructions from regarding the bank account (e.g. make a payment, close the account).
• Beneficiary. The legal person who is owed the funds that are held in the account.

note

You can’t have more than one legal person per relationship, per bank account.

Which one am I?

You are always the controller. Your organisation is always assigned to the controller relationship by default. You can open accounts, close accounts, and make payments. Any requests from owners must go through you.

Whether or not you are the owner of bank account depends on your business model. If your product or service involves opening bank accounts on behalf of others, you will be the controller but not the owner of those accounts.

Your organisation is the beneficiary of your operational accounts.

By definition, your organisation cannot be the beneficiary of a safeguarding and client money account.

	Operational account	Safeguarding or client money accounts - Dedicated model	Safeguarding or client money accounts - Pooled model	Savings account
Controller	You	You	You	You
Owner	You	You or your customer	You or your customer	Your customer
Beneficiary	You	Your customer or your customer’s customer	n/a	Always the same as owner

Relationship rules

For all bank accounts, our platform enforces rules about relationships. For example:

• For operational accounts, the legal person representing your organisation must occupy all three relationships.
• For savings accounts, the owner and beneficiary are always the same, so a beneficiary does not need to be specified.
• In the dedicated account model, the owner and beneficiary cannot be the same.
• Pooled accounts do not have beneficiaries. This is because they hold money belonging to multiple customers. Since we cannot define a single legal person as the beneficiary, we leave this field empty and flag the funding type as pooled. The rules for controllers and owners still apply.